Washington Update, March 2019

This week Apexus published a new version of a Frequently Asked Question (FAQ) related to HTCs and the GPO exclusion for hospitals. In the past, HTCs and their related hospital partners struggled to understand previous versions of the FAQ. As such, the Hemophilia Alliance worked with Apexus to update FAQ #2653 to hopefully increase clarity on the policy. FAQ #2653 now reads as follows:

FAQ ID: 2653

Last Modified: 03/07/2019

Q: May a Hemophilia Treatment Center (HTC) that is part of a hospital participate in a GPO for outpatient drugs?

A: The answer depends on how the HTC is registered with respect to the hospital.

If the HTC is otherwise an eligible entity and registered as such (with a 340B identification number beginning with HM), then it is not subject to the GPO prohibition and may purchase covered outpatient drugs through a GPO arrangement through its HTC 340B ID and account. This is true whether the HTC is within the four walls of a parent hospital subject to the GPO prohibition or located at an off-site outpatient clinic of a hospital subject to the GPO prohibition. However, in no circumstances may a hospital use the HTCs GPO to circumvent the GPO prohibition.

If the HTC is not registered for the 340B Program as a child site of the hospital, it may use a GPO for covered outpatient drugs provided that it meets all of the following: 1. Is located at a different physical address than the parent; 2. Is not registered on the 340B OPAIS as participating in the 340B Program; 3. Purchases drugs through a separate pharmacy wholesaler account than the 340B participating parent; and 3. The hospital maintains records demonstrating that any covered outpatient drugs purchased through the GPO at the HTC are not utilized or otherwise transferred to the parent hospital or any outpatient facilities registered on 340B OPAIS.

On March 1, the Alliance submitted its response to the Senate Health, Education, Labor and Pensions (HELP) Committee’s recent request for information from stakeholders on policy ideas to lower health care costs and improve health outcomes. The Alliance provided the Committee with some of the same recommendations that we sent to the Trump Administration in response to the Drug Pricing Blueprint as well as policies that support access to HTC clinical and pharmacy services for patients with bleeding disorders. A copy of the letter can be found on the Alliance website.